MEMORANDUM

SUBJECT: Incorporating Voluntary Stationary Source Emission Reduction 

Programs Into State Implementation Plans - FINAL POLICY

FROM: John Seitz, Director

Office of Air Quality Planning and Standards 

TO: Air Division Directors, Regions 1- 10

Introduction

This memorandum transmits the Environmental Protection Agency’s (EPA) final policy

regarding the granting of explicit State Implementation Plan (SIP) credits for voluntary stationary source

emission reduction programs under section 110 of the Clean Air Act (CAA). Voluntary stationary

source measures have the potential to contribute, in a cost-effective manner, emission reductions

needed for progress toward attainment and maintenance of the National Ambient Air Quality Standards

(NAAQS). The EPA believes that SIP credit is appropriate for voluntary stationary source measures

where we have confidence that the measures can achieve emission reductions. The attached policy

provides the details that States need to know in order to obtain these credits.

This policy is intended to complement the voluntary mobile source emissions reduction policy

that has been in place since October, 1997. It does not alter in any way the provisions of the mobile

source policy.

Policy Summary

The following is a summary of the key elements of the stationary source voluntary measures

policy:

Policy Target: The major targets of this policy are small, area sources that are not currently

regulated under the CAA. However, other sources may utilize this policy except in the case of

an area whose nonattainment problem is strongly affected by one source or a small group of

sources.

Meeting Other CAA Requirements: Voluntary measures may not be used to meet other

CAA requirements such as Reasonably Available Control Technology (RACT) requirements or

Best Available Control Technology (BACT) requirements. In addition, existing permit or SIP

requirements on sources cannot be converted to voluntary measures.
Types of Measures Allowed: Voluntary measures could be continuous, seasonal, or, for

retail/consumer measures, episodic. 

Enforceability: Voluntary measures are not directly enforceable against the source(s)

implementing the measures. If measures are not implemented as planned, or if the measures do

not achieve predicted emission reduction levels, then the State is responsible for remedying the

shortfall. 

Basic Program Requirements: In order to be approvable as a SIP revision, a stationary

source voluntary measures program could not interfere with other requirements of the CAA,

would need to be consistent with SIP attainment, maintenance or reasonable further progress

(RFP)/rate of progress (ROP) requirements, and provide emission reductions that are

quantifiable, surplus, permanent and enforceable (enforceable against the State, not against the

source).

Limitations: An area’s limit for stationary source voluntary measures is 3 per cent of the

needed reductions for ROP, RFP, or attainment demonstration purposes. This amount is in

addition to the 3 per cent limit that currently applies to mobile source voluntary measures.

Program Evaluation and Remediation: States must enforceably commit to complete an

initial evaluation of the effectiveness of each voluntary measure not later than 18 months after

putting the measure in place. In addition, States must also enforceably commit to correct any

shortfall between predicted and actual emission reductions within an additional 2 years.

Policy Evaluation: We plan to evaluate the effect of this policy after 5 years to determine if it

is meeting its goals. 

Please share this policy with your States, Tribes and local agencies. Any questions on the

policy should be addressed to Eric Crump, Office of Air Quality Planning and Standards, at 919-541-

4719.

Attachment

cc: M. Oge, OTAQ

B. Buckheit, OECA

A. Eckert, OGC

W. Becker
bcc: L. Wegman

W. Harnett

S. Shaver

D. Mobley

T. Helms

J. Paisie

R. Evans

R. Ossias

I. Spons

G. Whitfield

J. Clark

A. Davis

T. Curran

Voluntary Measures Work Group members
1

 “State means a State, local agency, Tribe or other entity that has the authority to submit an

implementation plan to EPA for approval under section 110 of the Act.

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Stationary Source Voluntary Measures Final Policy

(Note: As used in this document, the terms “we”, “us” and “our” refer to EPA. The terms “you” and

“your” refer to a State or States.)

Why have we developed a stationary source voluntary measures policy?

Many areas of the country that are designated as nonattainment are finding it increasingly

difficult to find ways to achieve additional emission reductions needed to attain the National Ambient

Air Quality Standards (NAAQS). Many areas have already applied reasonably available control

technology (RACT) and other controls to stationary sources and are still not attaining the NAAQS. In

some cases, areas have chosen to control sources well beyond RACT levels, but still cannot attain the

standards. These areas need to find additional innovative emission reduction approaches. One way to

accomplish this is through voluntary measures. Voluntary measures are an alternative to traditional

command and control approaches that have the potential to encourage new, untried and cost-effective

approaches to reduce emissions.

What is a voluntary measure?

As discussed in this policy, a voluntary measure is an action by a source that will reduce

emissions of a criteria pollutant or a precursor to a criteria pollutant that the State could claim as an

emission reduction in its State Implementation Plan (SIP) for purposes of demonstrating attainment or

maintenance of the NAAQS, reasonable further progress (RFP), or rate of progress (ROP), but that is

not directly enforceable against the source. Voluntary measures could not be used by the source to

meet any other emission reduction requirement (for example, offsets for New Source Review or credits

for trading under an economic incentive program). Voluntary measures also could not be used to meet

any other emission reduction requirement such as RACT, Best Available Control Technology (BACT),

Best Available Retrofit Technology (BART), Lowest Achievable Emission Rate (LAER), New Source

Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants

(NESHAP) limits. In effect, the source accrues neither liability nor direct benefit from the action. All

voluntary emission reductions would be credited to the State1 for demonstrations of attainment,

maintenance or RFP/ROP. 

Even though an individual source would not receive direct benefit from participating in a

voluntary measures program, there would still be incentives for sources to participate. These include a

desire on the source’s part to contribute to improved air quality, possible recognition by the State or

others of the source’s contribution to air quality improvement, and the opportunity to participate in a
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non-regulatory program for a small group of sources that may achieve emission reductions in a more

cost-effective and less resource-intensive manner.

What is a “source” as discussed in this policy?

For ease of reference, the term “source” refers to any non-mobile emitter of a criteria pollutant

or a precursor to a criteria pollutant. This includes major and area sources, including farms, natural

sources of pollutants such as blowing dust, retail stores and individual consumers. 

What sources does this policy cover?

Under this policy a State could take credit for voluntary measures that apply to the following

types of sources:

• Subject to the limitations described later in this policy, stationary sources or emission points

within a stationary source including any building, structure, facility or installation which emits or

may emit an applicable criteria air pollutant or precursor.

• Area sources that are too small and/or too numerous to be individually included in a stationary

source emissions inventory. This category could include facilities that directly emit applicable

criteria pollutants or their precursors such as very small printers or bakeries. It could also

include products sold by wholesale or retail operations that may emit criteria pollutants or their

precursors and individual consumers that may use products which emit criteria pollutants or

their precursors. 

Could all sources use the stationary source voluntary measures policy?

EPA would not consider it appropriate for all sources to participate in the voluntary measures

policy. Some nonattainment problems (whether area-wide or part of the larger nonattainment area) are

strongly affected by one source or a small group of sources. This is usually the case in nonattainment

areas for lead and sulfur dioxide (SO2), and for certain particulate matter (PM) and carbon monoxide

(CO) nonattainment areas as well. It should not be the case for ozone, where a mix of major sources,

area sources, mobile sources and long range transport all contribute to the problem. We do not believe

that sources which strongly affect a nonattainment problem should be allowed to participate in a

voluntary measures program. Emission reductions in these cases should be directly enforceable against

the sources causing the problem.

Could existing requirements be made “voluntary”?

Existing permit or SIP requirements on sources cannot be converted to voluntary measures. 

This “antibacksliding” provision is meant to ensure that currently required and enforceable activities
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cannot be made “voluntary.” 

What is the relationship of this policy to the mobile source voluntary measures policy?

 This policy does not cover any of the emission sources included in the mobile source voluntary

measures program, including on-road and non-road vehicles. Those sources are covered by the mobile

source voluntary measures guidance signed October 27, 1997. However, the stationary source

voluntary measures program does represent an extension of the basic policies developed in the mobile

source voluntary measures guidance to the stationary source arena. 

What is the relationship of this policy to the Economic Incentive Program (EIP)?

Economic incentive programs differ from voluntary measures in that under a State’s EIP,

emission reductions (or actions leading to emission reductions) must either be identifiable and

enforceable against a specific source or the State must use one of the following three methods to meet

the enforceability requirement:

• the EIP submittal includes fully adopted contingency measures and contains a State commitment

to automatically implement contingency measures, if necessary.

• the State will only count emission reductions on a retrospective basis.

• the State has used the control strategy in a similar situation, has achieved positive results, and

gets preliminary approval from the relevant EPA Regional Office to use the provision.

Some strategies might be originally approved under the voluntary measures policy and later,

after program evaluations have been completed, be able to be approved as a regular EIP. If an

emission reduction strategy can meet the EIP requirements, a State should strive for the strategy to be

approved as an EIP rather than as a voluntary measure because EIP measures have a greater degree of

certainty since they are more quantifiable than voluntary measures and are enforceable against the

source. Also, EIP measures are not subject to a limitation as are voluntary measures. 

What are the different types of stationary source voluntary measures programs?

Voluntary measures could be continuous, seasonal (in effect only during the season in which an

area experiences high pollutant concentrations) or, for certain actions, episodic (implemented during

specific periods of high pollutant concentrations, varying by meteorological conditions). 

What are examples of types of stationary source voluntary measures?

 Some examples of voluntary measures could include:

• Retail operations agreeing not to sell high emitting volatile organic compound (VOC) products
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during the ozone season.

• Consumer-oriented programs to reduce the use of high emitting paints or other consumer

products during the ozone season or no paint days during periods of high predicted ozone

concentrations (Ozone Action Days)

• Deferring or reducing both consumer and industry maintenance involving high emitting

chemicals.

• Where it is not already required, improved operating practices or use of pollution prevention

approaches to reduce emissions, such as covering containers, reducing waste from operations,

or use of water-based systems for cleaning operations at stationary sources.

• Reducing emissions from emissions points not currently required to be controlled (e.g., by

applying new or innovative emission reduction approaches such as pollution prevention or

process changes). 

• Process changes to reduce emissions during the ozone season.

• No burn days for PM programs, e.g. wood stoves or agricultural burning.

• Programs to reduce electricity usage.

• Heat island programs to encourage activities that will reduce center-city temperatures during the

summer, e.g. replacing roofs with Energy Star-labeled roof products or planting shade trees.

• Emission reductions resulting from programs designed to educate consumers or sources about

the effects of their actions on the environment. This could also include emission reductions

resulting from mentoring programs where firms that are more experienced in air pollution

control activities could advise less-experienced firms on ways to reduce air pollution.

• Process or technology changes that result in substantially reduced emissions beyond those

mandated in a SIP or mandated by such control programs such as RACT, BACT, BART,

LAER, NSPS or NESHAPs. 

What basic requirements would a stationary source voluntary measures program need to meet?

In order to be approvable as a SIP revision, a stationary source voluntary measures program

could not interfere with other requirements of the Clean Air Act, would need to be consistent with SIP

attainment, maintenance or RFP/ROP requirements, and provide emission reductions that are:

1. Quantifiable - The voluntary measure emission reductions should be quantifiable and include

procedures to evaluate and verify over time the level of emission reductions actually achieved. 

2. Surplus - The emission reductions could not be required or assumed by an existing SIP or permit

and could not otherwise be relied on or required to meet any of the following:

• A technology-based requirement of the Act, including, but not necessarily limited to, RACT,

BACT, LAER, BART, NSPS or NESHAP limits. 

• Conformity-based requirements - for example, reductions needed to demonstrate conformity.

• Emission reductions used or needed for offset or netting purposes.
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• Other adopted State air quality programs not in the applicable SIP.

• Federal rules that reduce criteria pollutants (or their precursors) such as rules for reducing

VOCs promulgated under section 183 of the Clean Air Act (CAA).

In other words, you could not claim emission reductions that result from any other emission

reduction or limitation of a criteria pollutant or precursor that you are already required to have to attain

or maintain a NAAQS or satisfy other CAA requirements for criteria pollutants. In the event that

emission reductions relied on in a voluntary measure are subsequently required by a new air qualityrelated program, like one of those listed above, those emission reductions would no longer be surplus. 

3. Enforceable - While we have already stated that voluntary measures are not enforceable against the

source, the State would be responsible for assuring that the emission reductions credited in the SIP

occur. The State would make an enforceable commitment to monitor, assess and report on the

emission reductions resulting from the voluntary measures and to remedy any shortfalls from forecasted

emission reductions in a timely manner as discussed below.

4. Permanent - The voluntary program should be permanent unless it is replaced by another measure

(through a SIP revision) or the State demonstrates in a SIP revision that the emission reductions from

the voluntary program are no longer needed.

What is the authority for approving voluntary measures programs under the Clean Air Act?

The EPA would approve voluntary measures under the following sections of the Act:

• 110 and 172 regarding emission reductions needed to achieve attainment of the NAAQS.

• 182 regarding economic incentive provisions.

• 175A regarding maintenance plans.

In light of the increasing incremental cost associated with stationary source emission reductions

and the difficulty of identifying additional stationary sources of emission reductions, EPA believes that it

needs to stimulate innovative approaches to emission reductions. Consequently, EPA believes that it

may be appropriate and consistent with the Act to allow a limited percentage of the total emission

reductions needed to satisfy ROP, RFP and attainment and maintenance requirements to come from

voluntary measures. 

While this policy does not require that actions be enforceable against individual sources, it does

place clear responsibility on a State to ensure that the emission reductions take place. This includes a

commitment, under timeframes as discussed below, to evaluate the effectiveness of each measure and,

in the event the voluntary measure does not achieve the projected emission reductions, to remedy any

SIP shortfall by providing enforceable emission reductions from other sources or by showing that the

emission reductions are not needed to achieve attainment, maintenance or RFP/ROP requirements. 
2

 In this document, the term “stationary source” is generally used broadly to include any source

that is not a mobile source, including consumer actions. However, in this discussion of section 123, the

term “stationary source” is used in its more traditional, regulatory sense, which is narrower in scope and

does not include individual or retail actions. For examples of regulatory definitions of “stationary

source,” see 40 CFR 51.165(a)(1)(i), 40 CFR 51.166(b)(5), and 40 CFR 60.2.

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The enforceable emission reductions from other sources or “showing” would be accomplished through

a SIP revision. 

What limitations apply to voluntary measures programs?

 Because of the innovation involved in stationary source voluntary measures, our inexperience in

quantifying them, and the inability to enforce these measures against individual sources, EPA believes

that it is appropriate to limit the amount of emission reductions allowed in a stationary source voluntary

measures program. At this time, we believe an appropriate limit for stationary source voluntary

measures would be 3% of needed reductions for ROP, RFP, or attainment demonstration purposes. 

This is not 3% of an area’s total emission inventory. For example, if a State projects emissions in the

attainment year to be 100 tons per day over the emissions needed to show attainment, the State could

take credit for emission reductions from stationary source voluntary measures of up to 3 tons per day. 

In the case of maintenance demonstrations, voluntary measures can account for no more than 3% of the

reductions needed to demonstrate maintenance of the NAAQS. These maintenance-related voluntary

measures would be in addition to those measures that were previously adopted for attainment or

RFP/ROP determination purposes.

Section 123 of the Act limits the credit States can take for using dispersion techniques, which

include episodic and supplemental controls on emissions from stationary sources that vary based on

atmospheric or meteorological conditions. The EPA's regulations implement section 123 at 40 CFR

sections 51.100, 51.118, and 51.119. One of the purposes of section 123 is to make sure that

stationary sources2 do not rely upon intermittent controls in order to avoid the application of feasible

constant emission controls. In implementing the voluntary measures policy, States would need to take

care to avoid seeking SIP credit for episodic controls on stationary source emission activities that are

feasibly regulated through continuously or seasonally applicable emission controls. Under the policy,

EPA would not grant credit to any stationary source episodic control measure that falls within the

Agency's definitions of "dispersion technique" at 40 CFR 51.100(hh)(1)(ii) or "intermittent control

system (ICS)" at 40 CFR 51.100(nn), except as allowed by EPA's rules.

The EPA believes that section 123 should not, however, restrict credit for non-stationary

source episodic or supplemental emission reduction measures that apply to consumer actions or the use

of consumer products such as paints or hairspray, for which these controls may represent the only

feasible type of control. For example, EPA has formally determined that the use of smoke management
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in agriculture and silviculture practices, and episodic curtailment of residential wood combustion, are not

dispersion techniques limited by section 123. Moreover, EPA has explained that the use of dust

suppressants at stationary sources are not dispersion techniques, since these measures are triggered by

the rate of dust emissions rather than by varying atmospheric or meteorological conditions. Finally,

EPA has stated that seasonal controls that are implemented at pre-determined periods of the year and

that do not vary with atmospheric or meteorological conditions are not limited by section 123, even if

they apply to stationary sources.

How does a voluntary measure get SIP approval?

A State would submit a SIP to EPA which:

• identifies and describes the voluntary measure program

• contains projections of emission reductions attributable to the program, along with relevant

technical support documentation

• commits to State implementation of those parts of the measure for which the State or local

government is responsible

• commits to monitor, evaluate, and report the resulting emissions effect of the voluntary measure

• commits to remedy any SIP credit shortfall in a timely manner as described below if the

voluntary program does not achieve projected emission reductions

• meets all other requirements for SIP revisions under sections 110 and 172 of the Act.

See attachment 1 for a detailed description of the SIP approval process. 

How should a SIP authority calculate the credit to be obtained from a voluntary measure?

The stationary source voluntary measures policy applies to a wide variety of types of stationary

sources. While a State would need to carefully develop an emissions quantification protocol that best

fits each type of emissions source, the following generic protocol presents the basic components that

should be accounted for in any emission reduction quantification approach. 

• Identify the type of source or facility that will be involved in the emission reduction activity.

• Determine whether the emissions from these sources are already included in the emissions

inventory in the SIP. If they are not already in the SIP inventory, no credit could be given for

these sources unless the baseline is reassessed. If they are in the SIP inventory, determine the

baseline emissions from these sources.

• Fully explain the emission reduction technique, provide a detailed estimate of the amount and

type of emissions (e.g. VOCs, NOx, PM, etc.) that will be reduced. Provide a clearly

articulated methodology for how the emissions reduction estimates were derived .

• Identify the number of sources that will participate in the voluntary measure and provide

documentation as to how that number was derived and why the SIP authority believes it to be

accurate.
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• If there is uncertainty in either the amount of emission reduction that will be generated by the

emission reduction technique or the number of sources that will participate, the SIP authority

should apply an adjustment factor to reduce the estimate commensurate with the level of

uncertainty. The greater the uncertainty, the greater the adjustment factor. This could be in the

form of a percentage reduction to the estimate.

• If the sources are generally of the same size and emission rate, multiply the number of sources

participating by the amount of emission reduction estimated per source to determine the total

emission reduction to be applied to the SIP. 

-orIf the emission reduction can differ substantially from source to source, add the emission

reduction from each participating source to derive a total emission reduction and apply it to the

SIP. 

How should a State evaluate the emission reduction effectiveness of its voluntary measures programs?

Program evaluation is the process of retrospectively assessing the performance of your

voluntary measures program. The primary purpose of program evaluation is to evaluate the amount of

reductions actually realized through the program and to serve as a basis for adjustments to the program

if the original estimates of emission reductions are not being achieved. In your SIP submittal, you would

develop and include specific program evaluation procedures for your voluntary measures program. 

You should carefully consider what approach can provide the most effective means to

accurately evaluate your voluntary measures program. Your approach will depend greatly on what

type of voluntary program you evaluate. For example, if you evaluate a low VOC retail paint sales

program, you may want to use inventory records to evaluate the program. For an ozone action day

approach to discourage use of VOC based consumer products (paints, hair spray, etc.), you may want

to use a consumer survey. Statistical sampling may be an appropriate method for assessing program

effectiveness, particularly for those voluntary measures utilized in the consumer/retail area.

How often should a State evaluate its voluntary measures program?

The State would enforceably commit to complete an initial evaluation of the effectiveness of

each measure not later than 18 months after putting the measure in place (one year to run the measure

and 6 months to analyze the data to determine the measure’s effectiveness). This evaluation should be

done more quickly, where possible. For instance, for a seasonal voluntary measure program that may

only run for 6 months, the timeframe may be 6 months to run the program and 6 months to determine its

effectiveness. 

Once a State has determined the initial effectiveness of its voluntary measure, it may reevaluate

its voluntary measure programs at the same time as other SIP measures, generally every 3 years, except

that if no requirement to reevaluate SIP measures applies to the particular plan, the State would need to
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reevaluate its voluntary measure programs at least every three years. If, before the required initial

evaluation or the scheduled reevaluations, the State becomes aware that the voluntary measure program

is not achieving or will not achieve the predicted emission reductions, the State should notify EPA and

correct the SIP as discussed in the next section.

What should a State do if the evaluation reveals a shortfall between predicted and actual emissions

reduction?

 

Your voluntary measures SIP submittal would include an enforceable commitment that if you

learn through program evaluations (or by other means) of a shortfall (i.e., projected emission reductions

were not or will not be achieved), you will correct the problem by providing enforceable emission

reductions from other sources or showing that the emission reductions are not needed for attainment,

maintenance or RFP/ROP. The enforceable emission reductions from other sources or “showing”

would be accomplished through a SIP revision.

Any shortfall would need to be corrected as soon as possible but could not exceed a year from

the completed program evaluation (or learning of the shortfall) if State rulemaking is not required. If

State rulemaking is required, you should proceed as expeditiously as possible under the required State

process, but you would need to correct the shortfall within 2 years. If the emission reductions from the

voluntary measure are necessary to be able to make a showing of attainment or ROP, your timeframe

to correct a shortfall could not exceed the statutory attainment or ROP milestone date for your

nonattainment area (for example, in the one hour ozone program, 2005 or 2007 for severe areas and

2010 for the extreme area). Failure to address this shortfall could lead to a finding of

nonimplementation under section 179(a)(4) of the Act. In such a case, sanctions may be imposed

under section 179(b) of the Act. 

How long does this policy last?

Because this policy is new and innovative, the EPA plans to evaluate the effect of this policy

after 5 years to determine if it is meeting its goals. During this evaluation, EPA will consider making

whatever changes to the policy are appropriate.

Disclaimer

The Clean Air Act and implementing regulations at 40 CFR Part 51 contain legally binding

requirements. This policy document does not substitute for those provisions or regulations, nor is it a

regulation itself. Thus, it does not impose binding, enforceable requirements on any party, and may not

apply to a particular situation based upon the circumstances. EPA and State decision makers retain the

discretion to adopt approaches to the approval of SIP measures that differ from this guidance where

appropriate. Any final decisions by EPA regarding a particular SIP measure will only be made based

on the statute and regulations. Therefore, interested parties are free to raise questions and objections
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about the appropriateness of the application of this guidance to a particular situation; EPA will, and

States should, consider whether or not the recommendations in the guidance are appropriate in that

situation. This guidance is a living document and may be revised periodically without public notice. 

EPA welcomes public comments on this document at any time and will consider those comments in any

future revision of this guidance document. Finally, this document does not prejudice any future final

EPA decision regarding approval of any SIP measure.

Attachments 
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Attachment 1 - SIP APPROVAL PROCESS

General Submittal Requirements

A State would submit a SIP to EPA which 

• identifies and describes the voluntary program; 

• contains projections of emission reductions attributable to the program, along with relevant

technical support documentation; 

• commits to monitor, evaluate, and report the resulting emissions effect of the voluntary measure; 

• commits to remedy in a timely manner any SIP credit shortfall if the voluntary program does not

achieve projected emission reductions, 

• meets other requirements for SIPs such as 

-- a showing that the State has legal authority. For example, the evidence may be a letter from

the State’s Attorney General’s office providing an analysis of the legal authority to adopt and

implement the State program under State law. -- the date of adoption, as well as the effective

date of the program, if this information is not already included in the program.

-- evidence that the program is consistent with the provisions of section 110(a)(2)(E) of the

Act.

-- include a copy of the voluntary measure, including indications of the changes made to the

existing approved SIP where applicable. The State program and other relevant rules would

have to be signed, stamped, and dated by the appropriate State official indicating that it is fully

implementable by the State. The effective date of the program should, whenever possible, be

indicated in the document.

• contains evidence that:

-- the State adopted the voluntary measure program into the appropriate State mechanism

(e.g., your applicable State rules) and the date adopted. 

-- the State followed all the procedural requirements in the State’s laws and constitution in

conducting and completing the voluntary measure program.

-- the State gave public notice of the proposed changes consistent with procedures approved

by EPA, including the date of publication of this notice.

-- the State held public hearings consistent with the information in the public notice and the

State’s laws and constitution.

--the State established explicit procedures for including the public in the program

implementation and evaluation phases, to address any environmental justice issues.

--the State has sufficient resources to collect data and perform a program evaluation to

determine the actual emission reductions realized by a voluntary measure.
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General Process Timeline

The general process timeline for getting your voluntary program approved consists of the following

steps:

• Develop the SIP revision in consultation with appropriate stakeholders - community (including

communities of concern), industry, academia, environmentalists and regulators. 

• Prepare documentation to support the SIP revision.

• Submit the SIP revision and supporting documentation to the applicable EPA Regional Office.

• The EPA Regional Office reviews the SIP submittal for completeness and decides whether the

SIP submittal is complete. 

• If the EPA Regional Office considers the SIP submittal to be incomplete, the EPA Regional

Office will return the SIP submittal. At this point, the State may revise the SIP submittal and

resubmit the package. 

• The EPA proposes action on the SIP revision in the Federal Register and takes comments on

the SIP from the public. Based on the public’s comments, the EPA may ask that the State

make changes in the SIP revision.

• The EPA publishes the final approval of the (original or modified) SIP revision in the Federal

Register.
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Attachment 2 - Mobile Source Voluntary Measures Policy

10/24/97

MEMORANDUM

SUBJECT: Guidance on Incorporating Voluntary Mobile Source Emission Reduction Programs in

State Implementation Plans (SIPs).

FROM: Richard D. Wilson,

Acting Assistant Administrator

 for Air and Radiation

TO: EPA Regional Administrators, 1 - 10

Introduction

This memorandum provides guidance and sets forth the Environmental Protection Agency’s

(EPA) policy and interpretation regarding the granting of explicit State Implementation Plan (SIP)

credit for Voluntary Mobile Source Emission Reduction Programs (VMEPs) under section 110 of the

Clean Air Act. Voluntary mobile source measures have the potential to contribute, in a cost-effective

manner, emission reductions needed for progress toward attainment and maintenance of the National

Ambient Air Quality Standards (NAAQS). EPA believes that SIP credit is appropriate for voluntary

mobile source measures where we have confidence that the measures can achieve emission reductions. 

This memorandum announces EPA’s intent to grant emission reduction credits for VMEPs, the terms

and conditions for establishing and implementing VMEPs, and the requirements for approvable VMEP

SIP submittals. 

 The establishment of this policy pertains solely to voluntary mobile source programs and is not

intended to establish precedent for other air emissions source categories. Guidance on emission

reduction credits for voluntary activities for other source categories may be established through future

guidance documents. This policy also does not change existing EPA policy on credits for mobile

source measures in the context of emissions trading programs or Economic Incentives Programs.
1

Throughout this document, the term “State” refers to any state or local government body or agency with

the authority to submit SIPs to EPA for approval.

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Policy Summary

The Clean Air Act Amendments of 1990 increased the responsibility of States1 to demonstrate

progress toward attainment of the NAAQS. At the same time, air pollution control programs in the

U.S. have had difficulty regulating the emission reduction potential of smaller or unconventional sources. 

EPA supports innovative methods in achieving air quality goals and wishes to promote the creation of

viable voluntary mobile source air quality programs. The desire to recognize the emission reductions

from these sources has led the Agency to develop policies to support an increasing variety of innovative

approaches. EPA recognizes that emission reduction credit toward SIP air quality demonstrations can

be a positive factor for gaining political and institutional support for program development and

implementation. The demonstration of air quality benefits is also desirable for program assistance

through EPA’s section 105 grants and is a requirement for project eligibility under the Department of

Transportation’s Congestion Mitigation and Air Quality Improvement (CMAQ) program.

 This memorandum is intended to clarify the basic framework for ensuring that VMEPs

become eligible for SIP credit. Generally, a State would submit a SIP which 1) identifies and describes

a VMEP; 2) contains projections of emission reductions attributable to the program, along with relevant

technical support documentation; 3) commits to monitor, evaluate, and report the resulting emissions

effect of the voluntary measure; and 4) commits to remedy in a timely manner any SIP credit shortfall if

the VMEP program does not achieve projected emission reductions. 

 EPA anticipates that this policy will generate additional interest and resources toward

VMEP development and data collection. EPA wishes to ensure that the potential benefits of VMEPs

are properly quantified and that these benefits are sustained as successful components of the SIP. As

experience and information regarding the effectiveness of VMEPs becomes available, EPA intends to

provide further technical guidance and assistance to the States. As States and EPA gain more

experience with VMEPs in quantifying emissions benefits, more precise information will be available in

determining the effectiveness of a range of programs. The type of information that EPA expects to gain

from evaluating VMEPs includes emissions benefits, public response and education, cost of

implementation, secondary indicators\benefits, quantification methodologies, and data collection. 
Page 15

EPA hopes that the effect of this policy will be to generate sufficient information and

programmatic experience to warrant a wider application of VMEPs for progress toward attainment

under the new NAAQS policy framework. EPA believes that States should benefit from this policy by

having a wider range of programmatic options to consider. This policy will ultimately support the

creation of new, cost-effective air quality programs and market-based incentives.

Background

Historically, mobile source control strategies have focused primarily on reducing emissions per

mile through vehicle and fuel technology improvements. Tremendous strides have been made resulting

in new light-duty vehicle emission rates which are 70 to 90 percent less than for the 1970 model year. 

However, transportation emissions continue to be a significant cause of air pollution due to a doubling

of vehicle miles traveled (VMT) from 1970 to 1990, and tripling since 1960. In some quickly

developing urban areas, the more recent VMT growth rate is even more dramatic. In San Diego,

California, VMT tripled between 1970 and 1990. VMT in Las Vegas, Nevada, increased 160 percent

from 1981 to 1991, and nearly doubled in Phoenix, Arizona, during the same time period.

The increasing cost of technological improvements to produce incrementally smaller reductions

in grams per mile or grams per kilowatt hour emissions in the entire fleet of vehicles and engines, along

with the time it takes for technological improvements to penetrate the existing fleets, suggests that

supplemental or alternative approaches for reducing mobile source air pollution are necessary. Mobile

source strategies which attempt to complement existing regulatory programs through voluntary,

nonregulatory changes in local transportation sector activity levels or changes in in-use vehicle and

engine fleet composition are being explored and developed. 

A number of such voluntary mobile source and transportation programs have already been

initiated at the State and local level in response to increasing interest by the public and business sectors

in creating alternatives to traditional emission reduction strategies. Some examples include economic

and market-based incentive programs, transportation control measures, trip reduction programs,

growth management strategies, ozone action programs, and targeted public outreach. These programs

attempt to gain additional emissions reductions beyond mandatory Clean Air Act programs by engaging

the public to make changes in activities that will result in reducing mobile source emissions.
 

2

The requirements regarding emission reductions needed to achieve attainment of the NAAQS.

Page 16

Definitions

The following definitions apply to VMEPs as described in this memorandum.

Voluntary Measures: Emission reduction programs that rely on voluntary actions of

individuals or other parties for achieving emission reductions.

Seasonal Measures: Emission reduction programs that are in effect only during the season in

which the area experiences high pollutant concentrations.

Episodic Measures: Activity-based mobile source programs that are implemented during

identified periods of high pollutant concentrations, varying by meteorological conditions. These

measures may or may not be continuous in nature depending on program design. The statutory

authority for approval of episodic measures in SIPs applies only to activity-based mobile source

emission reduction measures as explained below.

Clean Air Act Authority

EPA plans to use its authority under the Clean Air Act to allow SIP credit for new approaches

to reducing mobile source emissions. This policy represents a flexible approach regarding the SIP

requirements set forth in section 1102, and economic incentive provisions in section 182 and 108 of the

Act. This policy responds to State and local government interest in gaining SIP credits and funding for

VMEP programs which will count toward their State’s plan to make progress toward attainment and

maintenance of the NAAQS and builds on EPA’s history of approving measures that rely to some

degree on voluntary compliance, such as provision of mass transit. Recognizing that only a limited

amount of implementation experience currently exists, and that information on VMEP effectiveness will

be evaluated and reported as a result of this policy, EPA plans to re-evaluate this policy in the future.

Authority to approve of voluntary measures in SIP

EPA believes that it has authority under CAA section 110 to approve voluntary measures in a

SIP for emission reduction credit. However, EPA believes that as part of its SIP submittal a State must

commit to monitor, evaluate, and report the resulting emissions effect of the voluntary measure, whether

the measure is implemented directly by the State or another party, and to remedy in a timely manner

any credit shortfall.

In light of the increasing incremental cost associated with additional mobile source emission

reductions, the lead time required for new technologies to penetrate fleets, and the increasing need to
 

3

For example, an ozone area classified as severe needing reductions of 200 tpd of volatile organic compounds

(VOC) and 100 tpd of oxides of nitrogen (NOx) from the projected year 2005 baseline inventory could rely on VMEPs

for up to 3% of the required reductions from each pollutant, or 6 tpd of VOC and 3 tpd of No x. The area could also

use all or a portion of these same reductions for purposes of meeting interim rate-of-progress (ROP) milestones, but

again the 3% limit would apply. Thus, if the area needed 25 tpd of creditable VOC reductions to meet the 1999 ROP

target, no more than 0.75 tpd of the VOC reduction in the 1999 ROP plan could come from VMEPs.

 

4

In accordance with the Act language (section 182 (g)(4)(A)), the EIP applies to “incentives and requirements to

reduce vehicle emissions and vehicle miles traveled,” including TCM’s contained in section 108 of the Act. In

Page 17

target mobile source use to realize reductions, where voluntary measures meet the requirements of this

policy, EPA believes that it is appropriate and consistent with the Act to allow a limited percentage of

the total emission reductions needed to satisfy any statutory requirement, as described below, to come

from voluntary measures. In the event the voluntary measure does not achieve the projected emission

reductions, the State, having previously committed in its SIP to remedying such shortfalls, will pursue

appropriate follow-up actions in a timely fashion including, but not limited to: adjusting the voluntary

measure, adopting a new measure, or revising the VMEP emission credits to reflect actual emission

reductions, provided overall SIP commitments are met. EPA believes that voluntary mobile source

measures, in conjunction with the enforceable commitment to monitor emission reductions achieved and

rectify any shortfall, meet the SIP control measure requirements of the Act.

Establishment of a cap on SIP credits allowed for VMEPs

Under this policy, in light of the innovative nature of voluntary measures and EPA’s

inexperience with quantifying their emission reductions, EPA is setting a limit on the amount of emission

reductions allowed for VMEPs in a SIP. The limit is set at three percent (3%) of the total projected

future year emissions reductions required to attain the appropriate NAAQS. However, the total

amount of emissions reductions from voluntary measures shall also not exceed 3% of the statutory

requirements of the CAA with respect to any SIP submittal to demonstrate progress toward, attainment

of, or, maintenance of the NAAQS3. EPA has analyzed a number of voluntary mobile source

programs which could be incorporated into a SIP. The emission reduction potential of these programs

is generally a fraction of one ton per day. A three percent limit on emission reductions from VMEPs

will allow areas to implement and claim SIP credit for a significant number of voluntary mobile source

programs. This cap still provides a sufficient incentive for developing and implementing VMEPs, while

setting a limit on the extent to which a SIP can rely on innovative programs with which we have had

limited experience.

Relationship to Economic Incentive Programs

 The 1990 Amendments statutorily required the Agency to develop Economic Incentive

Program (EIP) rules4. The EIP provides general SIP guidance for the adoption of incentive and other
addition, the EIP defines mobile sources to mean on-road (highway) vehicles (e.g., automobiles, trucks and

motorcycles) and non-road vehicles (e.g., trains, airplanes, agricultural equipment, industrial equipment, construction

vehicles, off-road motorcycles, and marine vessels). In certain cases, States are required to adopt EIP provisions

into their State Implementation Plan (SIP). The EIP also serves as guidance for all other States that choose to adopt

EIP provisions into their SIP as non-mandatory EIPs. In 1994, the Agency issued EIP rules and guidance (40 CFR

part 51 subpart U), which outlined requirements for establishing these programs.

Page 18

innovative programs. Some programs that depend on voluntary actions also require either State or

local government authorization to implement the program. In these cases, which include certain

transportation control measures such as congestion pricing programs, it may be more appropriate to

use the EIP authority to incorporate the measure into the SIP. Further, where emissions reductions are

expected to exceed the 3% limit, EPA would anticipate the State could use the EIP to incorporate

measures. If a State wishes to have a VMEP approved under the EIP program rules, EPA is willing to

work with the State to develop such a program.

Approval of Voluntary Measures into the SIP - Key Criteria

This section sets forth minimum criteria for approval of VMEPs into SIPs. These criteria 

require that the VMEP not interfere with other requirements of the Clean Air Act, be consistent with

SIP attainment and Rate of Progress requirements, and that emission reductions be:

1. Quantifiable - VMEP emission reductions must be quantifiable. The level of uncertainty in

achieving emission reductions must be quantified, and this uncertainty must be reflected in the projected

emission reductions claimed by the VMEP. VMEPs must also contain procedures designed to both

evaluate program implementation and to report program results as described in the section “Technical

Support for VMEPs” of this guidance. 

2. Surplus - The VMEP emission reductions may not be substituted for mandatory, required emission

reductions. States may submit to EPA for approval any program that will result in emission reductions 

in addition to those already credited in a relevant attainment or maintenance plan, or used for purposes

of SIP demonstrations such as conformity, rate of progress, or emission credit trading programs.

3. Enforceable - A State’s obligations with respect to VMEPs must be enforceable at the State and

Federal levels. Under this policy, the State is not responsible, necessarily, for implementing a program

dependent on voluntary actions. However, the State is obligated to monitor, assess and report on the

implementation of voluntary actions and the emission reductions achieved from the voluntary actions

and to remedy in a timely manner emission reduction shortfalls should the voluntary measure not achieve

projected emission reductions. As stated earlier, EPA anticipates that the State will take the steps it

determines to be necessary to assure that the voluntary program is implemented and that emission

reductions are achieved so that corrective SIP actions are not required. For example, the State may

want to sign a Memorandum Of Understanding (MOU) with the VMEP sponsors. 
Page 19

Any uncertainty in the emission reductions projected to be achieved by the VMEP must be

estimated and reflected in the emission reduction credits claimed in the SIP. As part of this submission,

the State must commit to conducting program evaluations within an appropriate time-frame. The State

must also report the resulting information to EPA within an appropriate time-frame in order to

document whether the program is being carried out, and emission reductions are being achieved as

described in the SIP submittal. Through the program evaluation provisions contained in this policy EPA

anticipates that States will discover any potential emission reduction shortfall in a timely manner and

appropriately account for such shortfall either by changing the program to address the shortfall,

adopting a new measure, or revising the VMEP’s emission credits to reflect actual emission reductions

achieved, provided overall SIP commitments are met. 

4. Permanent - Emission reductions produced by the VMEP must continue at least for as long as the

time period in which they are used by applicable SIP demonstrations. The VMEP need not continue

forever to generate permanent emissions reductions, but must specify an appropriate period of

implementation in the SIP. Voluntary actions in such a program, and the resulting emission reductions,

can be discrete (temporary) or continuous, depending on the nature of the program. For example, an

ozone action day program which takes effect over an ozone season, but calls for specific actions on

days when exceedences of the ozone standard are likely (i.e., episodic measures) is considered a

continuous program producing discrete (temporary) reductions, and therefore the reductions are SIP

creditable.

5. Adequately Supported - As with all SIP creditable programs, VMEPs must demonstrate

adequate personnel and program resources to implement the program.

Approval of Episodic Measures

EPA has concluded that episodic transportation control measures and other mobile source

related market response measures may be approved for SIP credit under the Act. Prior to the 1990

amendments to the Act, EPA believed that section 123 of the Act, which bars the use of dispersion

techniques in calculating emission limitations, might apply to all control measures, including

transportation and mobile source market controls. However, new language was added to the Act in

the 1990 amendments that EPA believes indicates a clear congressional intent to 

allow and even require the incorporation of episodic transportation and mobile source market response

programs in SIPs.

Several new requirements added to the Act in 1990 specifically require adoption of

transportation control measures as listed in section 108(f)(l) of the Act under certain circumstances. 

See, for example, section 182(c)(5) - Transportation Controls and section 182(d)(1) - Vehicle Miles

Traveled. Section 108(e) and (f) authorizes EPA to issue guidance on various types of transportation

control measures available for selection in the control programs required under section 182. Section
Page 20

108(f)(1)(B) identifies methods that contribute to reductions in mobile source related pollutants during

periods in which a primary NAAQS will be exceeded. Episodic transportation and market response

measures designed to operate during periods when ambient pollution levels are anticipated to exceed

the NAAQS clearly fall within the scope of these types of programs that Congress has authorized areas

to include in their section 182 transportation and vehicle miles traveled programs. 

EPA therefore concludes that any implication that section 123 may have applied to

transportation and mobile source market response programs under the Act as amended in 1977 has

been clarified by the Act as more recently amended in 1990 by the addition of the specific authorization

for adoption of any program identified in section 108(f) under the transportation control programs

required under section 182.

Technical Support for VMEPs

A State may take credit in its SIP for VMEPs only if they are quantifiable. VMEPs which are

thought to be directionally sound, but for which quantification is not possible cannot be granted credit. 

EPA believes that carefully designed and implemented VMEPs are quantifiable to the extent necessary

to grant SIP credit. 

All VMEP submittals must include documentation which clearly states how the sources from

which the reductions are occurring, are currently, or will be addressed in the emissions inventory, ROP

plan, and attainment or maintenance plan, as applicable. This documentation should include a

description of the assumptions used in estimating and tracking emissions and emissions reductions from

affected sources.

The following sections are intended to provide general guidance on the elements of emission

reduction calculation and evaluation procedures that must be addressed in a VMEP SIP submittal.

Emission Reduction Calculation

To receive SIP credit for a VMEP, the SIP submittal must contain a good faith estimate of

emission reductions, including technical support documentation for the conclusion that the measure will

produce the anticipated emission reductions. VMEP emission reduction calculations must account for

and be adjusted to reflect uncertainties in the program. The calculations must be adjusted to account

for two types of uncertainty:

compliance uncertainty - the extent to which the responsible party (a public or private

entity) will fully implement the VMEP program, and

programmatic uncertainty - the extent to which voluntary responses actually occur
Page 21

and/or the inherent uncertainties of program design. 

The State must adjust the VMEP calculation for compliance and programmatic uncertainty,

based on program design elements, and on the predictive quality of the information, data, and analytic

methodology used by the State to develop the projected emission reductions. The State must justify the

appropriateness of the adjustments in its VMEP SIP submittal, usually as part of the technical support

document.

The adjusted emission reduction estimate should be developed and justified by the State by

taking into account various elements of the VMEP program design. These elements could include, but

not be limited to: the voluntary mechanism upon which the program is based, such as public outreach

or reduced fares; the variability in emission rates from affected mobile sources; the extent of uncertainty

in the emissions quantification procedure; and the frequency and type of program evaluation,

monitoring, record keeping and reporting.

Evaluation Reporting Procedures

States which use VMEPs in their SIP must describe how they plan to evaluate program

implementation and report on program results in terms of actual emissions reductions. Program

evaluation provisions for VMEPs must be accompanied by procedures designed to compare projected

emission reductions with actual emissions reductions achieved. The timing of the evaluations must be

specified in the VMEP SIP submittal. The States and program sponsors will benefit from accurate and

complete evaluation reports. EPA expects that program evaluations and experience gained over time

will result in VMEP modifications to increase effectiveness. 

The State must provide timely post-evaluation reports to the EPA relevant to the SIP timeframe in which the emission reductions are being used. These reports may be used by EPA for the

purpose of reviewing subsequent SIP submissions required by the CAA, including but not limited to:

periodic inventories, rate of progress (milestone compliance demonstrations), attainment

demonstrations, and maintenance demonstrations.

EPA is working with State and local government representatives to develop methodologies

which would provide sufficient technical support for VMEP SIP submissions. As results become

available, EPA will provide technical guidance to assist in the development of VMEP emission

reduction estimates and program evaluation procedures. However, EPA’s policy is to recognize the

experience of State and local voluntary programs in quantifying emission reductions and evaluating

program results. Acceptable methodologies and procedures will not be limited to those developed by

EPA, and programs are encouraged to discuss technically sound alternative methods with EPA

Regional Office staff.
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VMEP Emission Reduction Use

As explained above, under Title I of the Clean Air Act, EPA is permitting a limited amount of

voluntary mobile source measures to be included in SIPs and FIPs and to be adopted for any criteria

pollutant in both nonattainment and attainment areas. VMEP emission reductions shall be limited in use

as determined by existing applicable SIP policy including offsets, Rate of Progress, attainment

demonstrations, baseline determinations, redesignation and maintenance demonstrations. 

Future Guidance and Regional Coordination

It is incumbent upon EPA Regional Offices and Headquarters to coordinate the implementation

of this policy through consultation and exchange of information. It will be necessary to determine the

appropriateness of individual VMEPs, applicability of emission reductions, development of

methodologies to estimate emission reductions (including the appropriateness of uncertainty

adjustments), peer review, and standardization of policy. To the extent that issues cannot be resolved

through ongoing coordination efforts between Regional and Headquarter offices, issues may be

ultimately raised through the SIP consistency process. EPA encourages early consultation between

project sponsors, planners, and EPA’s Regional offices during the development of VMEPs.

For further information on EPA’s policy on VMEPs or the guidance set forth in this

memorandum, contact Michael Ball of the Office of Mobile Sources, at 313-741-7897.

Attachments
Page 23

Examples of Voluntary Mobile Source

Emission Reduction Programs

The following are some examples which are representative of voluntary mobile source emission

reduction programs (VMEPs) that could be implemented and credited with emission reductions for SIP

related purposes. These programs can and have been designed to be implemented on an episodic,

seasonal, or a continual basis. More program examples and ideas may be found on the following

websites:

EPA Office of Mobile Source Smart Travel Resources Center web site

(www.epa.gov/omswww/strc.htm)

Market Incentive Resource Center (www.epa.gov/omswww/market.htm)

Episodic Measures Database (www.epa.gov/omswww/reports/episodic/study/htm)

Employer Based Transportation Management Programs

Various programs implemented by employers to manage the commute and travel

behavior of employees, such as: van pooling, car pooling, subscription buses, walking, shuttle

services, guaranteed rides home, alternative work schedules, financial incentives(transit passes

and subsidies) and on-site TDM support.

Work Schedule Changes

Changes in work schedules to provide flexibility to employees to commute outside of

peak travel periods, such as: telecommuting, flextime, compressed work weeks, staggered

work hours.

Area-wide Rideshare Incentives

Promotional assistance aimed at encouraging commuters to use alternatives to single

occupant vehicles, such as: marketing of ridesharing services, transit station shuttles,

computerized carpool matching, vanpool matching, program implementation assistance.

Parking Management

Management of parking supply and demand, such as: preferential parking locations for

carpools and vanpools, preferential parking prices for carpools and vanpools, fee structures

that discourage commuter parking, reduced parking for new developments.

Special Event Travel Demand Management
Page 24

Special plans to manage travel demand in effect during special events, defined as

destinations for a large number of vehicle trips which occur on a one-time, infrequent, or

scheduled basis(such as athletic events, festivals, and major entertainment performances). 

These measures could include parking management, remote parking connecting with transit or

shuttle services, efficient traffic routing efforts, public information and communications systems. 

Vehicle Use Limitations/Restrictions

Techniques to limit vehicle activity in a given geographic area or specified time period,

such as: auto restricted zones, pedestrian malls, traffic calming, no-drive days, commercial truck

restrictions on parking and idling.

Reduced Vehicle Idling

Measures to reduce the amount of time which vehicles spend in idle modes as part of

their overall operation, such as: reduced operations of drive-thru facilities such as banks and

fast-food restaurants, reduced construction of drive-thru facilities, programs that facilitate

reducing idling at truck stops, transfer facilities and loading docks at commercial developments.

Small Engine and Recreational Vehicle Programs

Measures targeted at reducing the frequency and duration of small engine and

recreational vehicle use. Other programs aim to shift the time period in which emissions

producing activities, such as lawn and landscape maintenance, take place so that the negative

impact on air quality is reduced. These measures are usually associated with episodic or

seasonal control programs with a significant component of public education and outreach to

encourage the voluntary change in activities.
Page 25

Example of a Voluntary Program

Program scenario: A State air quality agency is approached by a public utility to begin a lawn

mower buy back program. The State would like to take credit for the emissions reductions from this

private sector activity in it’s 15% plan. 

Up-front credit: The State would like to take credit predicting the effect of the program in

reducing emissions associated with replacing uncontrolled lawnmower emissions with electric -- non

polluting lawnmowers.

SIP Submittal

General Process

C State notifies EPA of it’s intent to take credit for voluntary lawnmower program. Includes

program information and technical support documentation and commitment to remedy any

emission reduction shortfall in a timely manner.

C Regional Office reviews and approves up-front credit after comments.

C Activity is conducted by the public utility.

C State verifies that the program achieved the predicted benefits and generates 

information for EPA review.

C Regional Office reviews the State SIP submission and determines that the credits have been

achieved as predicted. Also approved under milestone compliance.

Program Identification: State submits to EPA its intent to conduct or take credit for the voluntary

lawn mower buy back program in the SIP. The State will describe how the program or activity will

work in practice. In the submission, the State will describe the following program elements.

Program participants

How the program works

Activity effects

Emission effects

State commitment for evaluation, reporting, remedying emission credit shortfall

Technical support documentation

Program Participants The State will identify the sponsors of the program. In this case the public

utility. 

How the Program Works As part of the submittal the State will include a description of the basic
Page 26

program, predicted effect of the program on a given NAAQS criteria pollutant and a commitment to

evaluate the program over the desired period of implementation and remedy any emission reduction

shortfall in a timely manner. 

In the submittal, the State describes the basic program including how the utility intends to facilitate the

activity-- buy back of lawn mowers. On three consecutive Saturdays, the utility customers and

employees are able to bring in their gasoline powered lawnmowers and receive a voucher toward the

purchase of any new electric lawnmower.

Activity Effects The State will submit predicted and observed activity effects. Data will be generated

and analyzed which examines the predicted and actual effect of the program.

In this case, using information provided by the utility, the State estimates that 2000 lawnmowers would

be replaced by non-polluting electric mowers. 

Emission Effects Activity effects ultimately are translated into emissions benefit calculations (usually in

tons per day\per year).

The State would be given up-front credit for emission reductions in terms of HC, CO and other

NAAQS criteria pollutants for 2000 mowers being replaced by electric mowers.

State Commitment for Evaluation, Reporting, and Addressing Credit Shortfall The State will

be responsible for ensuring that data will be collected regarding participation and the effectiveness of

the program. In addition, the State must commit to remedy any SIP credit shortfall in a timely manner if

the voluntary measure does not achieve projected emission reductions. 

The State, as part of the evaluation and reporting commitment, submits to EPA a comparison of the

predicted effect of the program with the actual observed levels. In this example the utility finds that

2000 mowers were replaced. Thus, the predicted reductions were achieved.

Technical Support Documentation The State will submit Technical Support Documents describing

the program and the methodology for predicting emissions benefits. Where possible the State should

identify data collection methodologies and information necessary for describing implementation,

compliance, effectiveness and other relevant information. This information should account for the

following:

 

Programmatic Uncertainty- Because the program will be voluntary in nature, the State will be

responsible for submitting to EPA the predicted and, eventually, the actual participation levels. 

Analytic Methodology- The State will describe how they estimated participation levels and the
Page 27

effect of the activity on emissions.